Epstein Secrets

2 and 13); and Epstein’s medical records from Dr. Stephen Alexander (Request 16). Each of these categories

g required to produce or testify. Rudy-Glanzer v. Glanzer, 232 F.3d 1258, 1263 (9 Cir. 2000). Accordingly,

All medical records of Defendant Epstein from Dr. Stephan Alexander. Response: Defendant is asserting sp

quired to produce and/or testify. Rudy-Glanzer v. Glanzer, 232 F.3d 1258, 1263 (9th Cir. 2000)(the "privil

and 13); and Epstein's medical records from Dr. Stephen Alexander (Request 16). Each of these categories

e having a tendency to Incriminate Epstein and would threaten to invade his privilege against being required to produce or testify. Rudy-Glanzer v. Glanzer, 232 F.3d 1258, 1263 (9"' Cir. 2000). Accordingly, finding the sought after information would result in testimonial disclosures that would communica